Statute of limitations, including but not limited to:

• General 3 year assessment statute;
• 6 year assessment statute for 25% omissions;
• Disclosing items to prevent 6 year statute;
• Unlimited statute for false returns, returns attempting to evade tax, or no return;
• Resolving matters in appeal that removed the unlimited statute, and thus, removed the entire year’s assessments;
• Extension of time to statute of limitations pursuant to Form 872;
• Advising on issuance of statutory notice of deficiency and tolling of statute;
• General 10 year collection statute;
• Filing timely claims for refund within 3 years from the time the return was filed or 2 years from the date the tax paid, whichever is later;
• Adequacy of claim for refund, and successfully arguing the doctrine of variance;
• Filing formal and informal claims for refund;
• Advising on payments versus deposit distinction;
• Filing suits for denied claims for refund; and
• Arguing equitable recoupment, as well as mitigation provisions.